| Table 1: Annual Respondent Burden and Cost – NESHAP for Semiconductor Manufacturing (40 CFR Part 63, Subpart BBBBB) (Renewal) |
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122.2 |
153.55 |
61.51 |
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Updated labor rates |
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| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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Person hours per occurrence |
No. of occurrences per respondent per year |
Person hours per respondent per year |
Respondents per year a |
Technical person- hours per year |
Management person hours per year |
Clerical person hours per year |
Total Cost |
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(C=AxB) |
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(E=CxD) |
(Ex0.05) |
(Ex0.1) |
Per year b |
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| 1. Applications |
N/A |
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| 2. Survey and Studies |
N/A |
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| 3. Reporting requirements |
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| A. Familiarization with rule requirement |
4 |
1 |
4 |
1 |
4 |
0.2 |
0.4 |
$544.11 |
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| B. Process/review information d |
4 |
2 |
8 |
1 |
8 |
0.4 |
0.8 |
$1,088.23 |
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| C. Write Report |
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| Initial notification c |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of performance evaluation c |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of compliance status c |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Performance evaluation reports c |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Develop a startup, shutdown, malfunction (SSM) report e |
1 |
4 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| Develop a semiannual summary report f |
4 |
2 |
8 |
1 |
8 |
0.4 |
0.8 |
$1,088.23 |
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| Subtotal for Reporting Requirements |
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23 |
$2,721 |
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| 4. Recordkeeping requirements |
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| A. Familiarization with rule requirement |
See 3A |
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| B. Plan activities |
8 |
1 |
8 |
1 |
8 |
0.4 |
0.8 |
$1,088.23 |
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| C. Implement activities |
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| Control devices |
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| Design analysis |
15 |
1 |
15 |
0 |
0 |
0 |
0 |
$0 |
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| Performance evaluation |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| Equipment inspection |
1 |
52 |
52 |
0 |
0 |
0 |
0 |
$0 |
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| Monitoring activities |
1 |
52 |
52 |
0 |
0 |
0 |
0 |
$0 |
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| Maintenance |
2 |
52 |
104 |
0 |
0 |
0 |
0 |
$0 |
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| D. Develop record system |
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| Develop SSM plan |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| Control equipment/maintenance plan |
12 |
1 |
12 |
0 |
0 |
0 |
0 |
$0 |
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| E. Time to enter information |
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| Control equipment testing |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
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| Control equipment inspection |
0.5 |
52 |
26 |
0 |
0 |
0 |
0 |
$0 |
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| Control equipment monitoring |
0.5 |
52 |
26 |
0 |
0 |
0 |
0 |
$0 |
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| F. Time to train personnel |
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| Control equipment inspection and Monitoring |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| G. Store, file and maintain records g |
2 |
2 |
4 |
1 |
4 |
0.2 |
0.4 |
$544.11 |
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| H. Retrieve records/reports h |
2 |
2 |
4 |
1 |
4 |
0.2 |
0.4 |
$544.11 |
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| Subtotal for Recordkeeping Requirements |
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18 |
$2,176 |
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| TOTAL ANNUAL BURDEN AND COSTS (rounded) i |
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41 |
$4,900 |
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| TOTAL CAPITAL/O&M COST (rounded): i |
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$550 |
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21 |
hr/resp |
| GRAND TOTAL (rounded): i |
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$5,450 |
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| Assumptions: |
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| a We have assumed that there is approximately 1 existing major source currently subject to this rule. There will be no additional new sources that will become subject to the rule over the three-year period of this ICR. |
| b This ICR uses the following labor rates: $153.55 per hour for Managerial labor; $122.20 per hour for Technical labor, and $61.51 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021 “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. |
| c This is a one-time only activity. |
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| d We have assumed that it will take the respondent 4 hours twice a year to process and review information. |
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| e We have assumed that it will take each respondent 1 hour four times a year to write the startup, shutdown, malfunction (SSM) report. |
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| f We have assumed that it will take the respondent 4 hours two times a year to complete the semiannual report. |
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| g We have assumed that the respondent will take 2 hours two times per year to store, file and maintain records. |
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| h We have assumed that the respondent will take 2 hours two times per year to retrieve records/reports. |
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| i Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding. |
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| Table 2: Average Annual EPA Burden and Cost – NESHAP for Semiconductor Manufacturing (40 CFR Part 63, Subpart BBBBB) (Renewal) |
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51.23 |
69.04 |
27.73 |
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Updated labor rates |
| Activity |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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EPA person- hours per occurrence |
No. of occurrences per plant per year |
EPA person- hours per plant per year |
Plants per year a |
Technical person- hours per year |
Management person-hours per year |
Clerical person-hours per year |
Cost, $ b |
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(C=AxB) |
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(E=CxD) |
(Ex0.05) |
(Ex0.1) |
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| Review initial notification reports |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| Review notification of compliance status |
10 |
1 |
10 |
0 |
0 |
0 |
0 |
$0 |
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| Review semiannual summary reports c |
15 |
2 |
30 |
1 |
30 |
1.5 |
3 |
$1,723.65 |
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| Review notification of performance test d |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| Attend initial performance tests |
120 |
1 |
120 |
0 |
0 |
0 |
0 |
$0 |
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| Review test results e |
10 |
1 |
10 |
0 |
0 |
0 |
0 |
$0 |
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| TOTAL ANNUAL BURDEN AND COST (rounded) f |
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35 |
$1,724 |
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| Assumptions: |
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| a We have assumed that there is approximately one existing major source currently subject to this rule. There will be no additional new source that will become subject to the rule over the three-year period of this ICR. |
| b This cost is based on the following labor rates which incorporate a 1.6 benefits multiplication factor to account for government overhead expenses: $69.04 for Managerial (GS-13, Step 5, $43.15 x 1.6), $51.23 for Technical (GS-12, Step 1, $32.02 x 1.6), and $27.73 Clerical (GS-6, Step 3, $17.33 x 1.6). These rates are from the Office of Personnel Management (OPM) “2021 General Schedule” which excludes locality rates of pay. |
| c We have assumed that the respondents will take 15 hours two times a year to review the semiannual summary reports. |
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| d We have assumed that it will take each respondent 4 hours one time a year to review notification of performance tests. |
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| e We have assumed that it will take each respondent 10 hours one time a year to review test results. |
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| f Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding. |
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